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Johnston July 19, 1994 -2- baseline soil depths, obtained from MCC's permit are multiplied by the disturbed areas of the mine as indicated on permit map #56. This is not an unreasonable request. MCC stated, in the response to concern No. 4, that "average topsoil salvage depth for each soil type is not a matter of record at the mine site." Page 2.05-44 of MCC's permit application states that "existing soil information will continue to be verified in the field before stripping. The actual stripping operations will be closely monitored in the field to insure that all useable topsoil is salvaged. Specific horizons and volumes to be removed will continue to be delineated at the time of top soil stripping." This is a commitment of their permit, why do they not have this data? The "Topsoil Salvage Monitoring Plan" on page 2.05-48 of MCC's permit application states that "if topsoil stripping depths are significantly less than that necessary to replace an average of 12-18 inches of seedbed quality material on the surface disturbed areas of the general mine site and 9-12 inches on the refuse disposal area, the regulatory authority will be notified." My calculations using MCC's baseline data (which should be updated if it is proven to be inaccurate) show that enough topsoil has been salvaged to replace an average of approximately 10.5 inches of material across the disturbed area.. This meets the average depth for the refuse disposal area but is far short of the 15 inch average depth for the other disturbed areas. In light of this information, I believe the Division is justified in asking for the average topsoil stripping depths. If MCC cannot provide them, they may be out of compliance with their permit. 4. In order to predict topsoil salvage volumes for disturbances at the West Elk Mine, all disturbed area boundaries need to be accurately marked on a baseline soil type map. As MCC disturbs new areas, the baseline data maps, including soils maps need to be updated to include the newly disturbed areas. 5. There are significant discrepancies in the location of the disturbed area boundaries shown on Map 57 and the boundaries shown on the Envirocon Map titled, Topsoil Reclamation, dated December 1, 1993. (I'm sure that MCC personnel can identify these discrepancies if they compare the boundaries).